Free Motion for Extension of Time - District Court of Connecticut - Connecticut

Case 3:02-cr-00014-AWT

Document 58

Filed 07/13/2006

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA VS. JULIO RODRIGUEZ : : : NO. 3:02CR14 AWT JULY 11, 2006

MOTION FOR ENLARGEMENT/EXTENSION OF TIME TO FILE CROSBY MEMORANDUM The defendant, JULIO RODRIGUEZ, by and through his undersigned counsel, Richard S. Cramer, pursuant to L. Civ. R. 7(b) and Fed. R. Crim. P. 45, and hereby moves this Honorable Court to enlarge/extend the time within which to file a Crosby memorandum, originally scheduled for submission on July 10, 2006, for the following reasons: 1. Defense counsel was preparing for a trial before this Court (United States v. Robert McCloud) on July 10, 2006. 2. Defense counsel has also been busy with State and Federal court appearances. 3. Defense counsel needs at least another week to complete the Crosby memorandum. 4. Defense counsel has not spoken with Assistant U. S. Attorney Raymond F. Miller who indicated that the Government has no objection with respect to this motion. Mr. Miller also requests an extension of one week within which to file his reply. WHEREFORE, the undersigned respectfully requests that this motion for

Case 3:02-cr-00014-AWT

Document 58

Filed 07/13/2006

Page 2 of 2

enlargement/extension of time be granted and that the time for filing a Crosby memorandum be enlarged/extended until Tuesday, July 18, 2006. Respectfully submitted, DEFENDANT, JULIO RODRIGUEZ

By:_______________________________ Richard S. Cramer 449 Silas Deane Highway Wethersfield, CT 06109 Tel. (860) 257-3500 Federal Bar No. ct00016 Email: [email protected] CERTIFICATON THIS IS TO CERTIFY that a copy of the foregoing was mailed postage prepaid this 11th day of July 2006 to: Raymond F. Miller Assistant U. S. Attorney P.O. Box 1824 New Haven, CT 06508

________________________________ Richard S. Cramer